Diana R. Esposito Chief-Assistant Attorney General records request

8/12/2019 Diana R. Esposito Chief-Assistant Attorney General records request

1/38

VIA Email: [email protected] August 8, 2014

Diana R. Esposito

Chief-Assistant Attorney General

Office of the Attorney General

501 East Kennedy Blvd., Suite 1100

Tampa, FL 33602

Dear Ms. Esposito:

This is a request for records regarding Sandra L. Burge. The attached employment application to

the Hillsborough County Courts for a paralegal/legal assistant position, signed by Sandra L.Burge June 4, 2012, shows Ms. Burge was previously a paralegal specialist to Diana R. Esposito,

Florida Chief-Assistant Attorney General, from December 1, 2005 through June 1, 2012, Office

of the Attorney General, Tampa Civil Division, 501 E. Kennedy Blvd., Suite 1100.

Enclosed is my records request letter July 28, 2014 to the Attorney General of Florida, and the

response letter August 4, 2014 by Leslie Jacobs, Public Records Coordinator. Ms. Jacobs

provided 196 pages of records in PDF on a CD-ROM at no charge. The records provided are

limited to the personnel file of Ms. Burge. The records are not responsive to the following,which I submit to you as a records request for you to provide the records,

2. Provide records for Sandra L. Burge and her current position, if any, with the Office of

the Attorney General.

3. Provide records for Sandra L. Burge for any other current or past employment with the

State of Florida.

4. If Sandra L. Burge is not employed by the State of Florida, provide records showing

her current employment, or her current employers mailing address.


2/38

VIA UPS No. 1Z64589FP298506078 July 28, 2014

Attorney General of FloridaOffice of Attorney General

State of Florida

107 West Gaines Street

Tallahassee, FL 32399-1050

PUBLIC RECORDS REQUEST, RE: Sandra L. Burge

This is a request for public records for Sandra L. Burge. An employment application to the

Hillsborough County Courts for a paralegal/legal assistant position, signed by Sandra L. Burge

June 4, 2012, shows Ms. Burge was previously a paralegal specialist to Diana R. Esposito,

Florida Chief-Assistant Attorney General, from December 1, 2005 through June 1, 2012, Office

of the Attorney General, Tampa Civil Division, 501 E. Kennedy Blvd., Suite 1100.

1. Provide records of the personnel file of Sandra L. Burge as a paralegal specialist to Diana

R. Esposito, Florida Chief-Assistant Attorney General, Office of the Attorney General, TampaCivil Division, 501 E. Kennedy Blvd., Suite 1100.

2. Provide records for Sandra L. Burge and her current position, if any, with the Office of


3. Provide records for Sandra L. Burge for any other current or past employment with the

State of Florida.

4. If Sandra L. Burge is not employed by the State of Florida, provide records showing her

current employment, or her current employers mailing address.


3/38

PAM BONDI

ATTORNEY GENERAL

STATE

O

FLORIDA

OFFICE OF THE ATTORNEY GENERAL

Executive Staff

PL-O

1 The Capitol

Tallahassee, FL 32399-1050

Phone (850) 414-3990 Fax (850) 487-2564

http://www myj1orida/ega/ com

August 4, 2014

Mr. Neil

J.

Gillespie

8092 SW 115

th

Loop

Ocala, FL 34481

Dear Mr. Gillespie:

This will respond to your July 28, 2014 letter in which, pursuant to Ch. 119, F.S., you

make the following request for public records:

1. Records of the personnel file of Sandra L. Burge as a paralegal specialist to Diana

R. Esposito, Chief Assistant Attorney General, Tampa Civil Division.

2.

Records for Sandra L. Burge and her current position,

if

any, with the Office of


3. Records for Sandra

L.

Burge for any other current or past employment with the

State ofFlorida.

4.

Records showing the current employment ofSandra L. Burge or her current

employer's mailing address.

5. Records of Sandra L. Burge's fraud and impairment of your Petition No. 12-7747

to the Supreme Court of the United States during her employment as a paralegal


4/38


5/38

KNOWLEDGE

SKILLS

ABILITIES

KIA.)

Ust

KSAs

you posse l

and

belleve

,elevant to the poaillon

you _ k such

IS

operating heavy

equipment.

computer skills,

fluency

in tanguage(s), etc.

EXEMPTION FROM PUBLIC RECORDS DISCLOSURE

ARE

YOU A

CURRENT OR FORMER LAW

ENFORCEMENT

OFFlCER,

OTHER EMPLOYEE"

OR THE SPOUSE :1:.'

OR CHILO OF ONE. WHO IS

EXEMPT

FROM PUBUC RECORDS DISCLOSURE UNDER 119.07, F.S.? 0 YES

01her covered jobs

lndude:

correctional

and oorrectionai probation

office,..

firefighters.

certain judges.

as&jstant state attorneys, state attorneys,

a ItItanl and

statewide prosecutors,

personnel

d

the

Department

of

Revenue

or locel

governments

whole

r e p o n l ~ i t i e

inetude revenue

collection

and

enforcement

or

chid

support enforcement, and ctrtaanlnvestigators tn the

Department

of Chldren and

Famll

(see

119.07,

F.S.).

BACKGROUND

INFORMATION

HAVE YOU

EVER

BEEN

CONVICTED

OF A

FELONY

OR A

FtRST DEGREE

MlSDeMEANOR?

DYES

If YES, what

charges?

Where convieted? _

Data

1 COnviction:

DYES

Date:

HAVE

YOU

EVER

HAD

THE ADJUDICATION OF

GUILT WITHHELD FOR A

CRIME

WHICH IS A

FELONY

OR A FIRST

DEGREE

MiSDEMEANOR?

DVES

f -Yes-, what charges?

Where?

_

Date:

NOTE: A

YES

answer to these questions will not

automatically

bar you from employment. The nature. JotHetatedness.

severity

and

date

of tile offense

in

reldon to

the

position

for which

you

... applying

are

considered.

CITIZENSHIP


6/38

PERIODS O EMPLOYMENT

Describe your WOfi experience in d.td begInning witn your

current

Of

moat

teC8fi job

lnctude

milUary

service

(lndica e rank)

and

)Ob--f.tated volunteer work. n

applicable.

Indicate numb. of

employ-

U

ttlook

to

cll

potltIon Of PI ' _ployfMftt. If needed. attach 1dctl1lonal ' t I , ulrng Itt, ........ format

u

on the application. U

Information

in thit section mUtt be completed.,.., may

be

to pro

..de

Iddltlonallnformatton.

Ruton For Leaving:

_

Name

of

Next

PrwIouI

Empfoyer:

_

Add

. . . . .

: _

PhoM No.: _

Your Job Title: _

SupeM.,r a Name: _

~ o ~

Duti

and

R

ponalbiUtie.:

ro:

O O ~ ~ R W n ~ ~ ~ - ~ ~ ~ - ~ ~ I ~ ~ ~ . ~ ~ ~ _ ~ o ~ ~ ~ ~ . ~ ~ ~ o ~ ~ . ~ -

_


7/38

Mameof

Next

P vloua Employer:

. _

Add

: _

Phone No.:

~

Your Job Title: _

Supervisor . Name: ~

FROU: U f t U r U I ~

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TO:

1 .1

. on

TUA

HOURS

PER WEEK:

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and Reaponalbmtlu: _

- - - - - - - - - - - - - - - _

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= ~ :

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Name 01 Next P1 evlou. Employer: - _

Addreu:

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Title: _

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FROM:

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TO:

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HOURS PER WEEK: __ (\- . ~ ~ ~ ~ ~ ~ ~

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ponaibiUtlea: _

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8/38


9/38


10/38

Name of Previous Employer:

I

t

Emploved

by

cboice

I

Address:

Supervisorls

Name:

From:

Duties and

Responsibil

ities:

nrolled

in Paralegal training and secured law

office

employment for some on the job

training.

Reason For Leaving:

Name

of PreviOUS

~ m p f o y e r :

b i rde K

c ~ r ~ r a t l o n

__ ~ _ ~ ~ ~ ~ ~ _ _ ~ ~ _ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~

11130 W t Warner Rd.

Te;noe AZ

85284-2816

a

......

e -r

ddress:

Your Job Title: ~ L I o i a l . l o . l n

o

..... _1

Phone No.:

upervisor's

Name:

kdo

oat

remember

b l72B B O O Q

I

Insert

I

From:

64/1997

To: llQ/2Q03

I

Hours Per

Week: ~ O 6 ha I


11/38

Name of

Previous Employer:

aroet

Stores 2 locations

in

Tamna El)

t 1

---


12/38

Name of Previous Employer:

I

- eenort

Memorial

Hosoital

Address:

Your Job Title:

birector of

Human Resources J

Supervisor s Name: hoe

n n ~

Phone

No.: ~ 8 1 5 5 9 9 6 0 0 0

Insert

J

From b8 19Bl

I

To bS 1987

I

Hours

Per

Week:

~ o

I

MM{YYYY) (MM/yyyy) (Your name If different during employment)

Supervised

staff

of 2; managed all human resource functions

for

700 bed hospital.

Duties and

Responsibilities:

Reason

For

leaving: rccepted consulting assignments.

Name of PreviOUS Employer:

Your Job Title:

Phone No.: I

I ~ e r t

I

Hours Per Week:

I

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______

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Address: It - _

S u p e ~ i s o ~ s

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From: I I To:


13/38

VIA U.P.S. No. 1Z64589FP294626428 May 16, 2013

and [email protected]

Kenneth V. Wilson, Assistant Attorney GeneralCivil Litigation Bureau -Tampa


501 E Kennedy Blvd., Suite 1100

Tampa, Florida 33602

RE: Missing Public Records, Gillespie v. Thirteenth Judicial Circuit, Florida, et al.

Petition No. 12-7747 for Writ of Certiorari, Supreme Court of the United States

Dear Mr. Wilson:

So sorry to see you got duped by court counsel David Rowland and paralegal Sandra Burge, who

misrepresented to you that I did not provide Mr. Rowland a copy of Petition No. 12-7747. That

must explain why the petition was not among the 323 pages of public records provided by your

office that arrived here in Ocala May 9, 2013 in response to my records request.

An email (Exhibit 1) from Mr. Rowlands paralegal Sandra Burge to Chief Assistant Attorney

General Diana R. Esposito 12/20/2012 at 12:51 PM, Cc to David Rowland and Chris Nauman,

advanced this material falsehood, which Ms. Esposito sent to you, Cc to Amanda Cavanaugh:

The Plaintiff's Notice of Filing the petition for writ of certiorari was received in the Legal

Department's Office on 12/18/12 is attached as well as the Court's docket indicating a

response is due, if needed, by January 14, 2013. Neither a copy of the petition nor

"separate Volume Appendices" accompanied the Notice.

A letter (Exhibit 2) emailed by you January 8, 2013 repeated the falsehood back to Mr. Rowland:


14/38

Kenneth V. Wilson, Assistant Attorney General May 16, 2013

Office of the Attorney General Page - 2

The document referred to by Ms. Burge in her deceptive email to Ms. Esposito was a Rule 12.3

notice, and notice of waiver to file a response, delivered December 18, 2012 at 10:44 AM to the

Thirteenth Judicial Circuit. Unfortunately Ms. Burge, Mr. Rowland, and Mr. Nauman failed toinform you that my petition was delivered a week earlier, December 11, 2012 at 10:55 AM.

The Thirteenth Circuit gang further mislead you by providing you my December 10, 2012 cover

letter to the Clerk of the Supreme Court which they date-stamped December 18, 2012, when this

letter was in fact a second courtesy copy of the one received by Rowland December 11, 2012 but

does not appear date-stamped as such in the records your office provided me May 9, 2013.

Enclosed you will find evidence showing I served by UPS the Rule 12.3 notice, and notice of

waiver to Mr. Rowland December 17, 2012 tracking no. 1Z64589FP291778029, which was

delivered December 18, 2012 at 10:44 AM, to the Courts address, 800 E. Twiggs Street, Tampa,

Florida. The UPS proof of delivery shows DAVIS at the front desk signed for the delivery. A

composite of the UPS proof of delivery and tracking documents is enclosed. (Exhibit 4).

The Supreme Court sent me three (s) sets of Rule 12.3 notices, and notices of waiver to file a

response, December 14, 2013 after my petition was docketed, with instructions for notifyingopposing counsel(s) that the case was docketed. (Exhibit 5).

You have my sympathy for any embarrassment caused by the deception of Mr. Rowland and his

accomplices, that caused an inaccurate letter to issue from the Office of the Attorney General

falsely implying I did not provide a copy of my petition to Mr. Rowland. (Exhibit 2).

Enclosed you will find my records request to Mr. Rowland intended to correct the record. If and

when I get an accurate response back, I will provide you the correct date-stamped petition forinclusion in the record showing it was received by Mr. Rowland December 11, 2012.


15/38

Fw: Gillespie v 13th JCC, et al: US Supreme Court/Response Due

Diana Esposito to: Kenneth Wilson

12/20/2012

01

:58 PM

Cc: Amanda Cavanaugh

History:

This message has been forwarded.

Ken, herets the newest email from Sandy - now paralegal assistant to David Rowland ... D

Diana R. Esposito

Chief-Assistant Attorney General

Civil Litigation Bureau


501 E. Kennedy Blvd, Suite 1100

Tampa, FL 33602

Tel: 813-233-2600, x110

Fax: 813-233-2886

----- Forwarded by Diana Esposito/OAG on 12/20/2012 01 :57 PM ----

From: "Burge.Sandra"

< b u r g e s ~ @ f l j u d

13.org>

To:

"[email protected]"

Cc: "Rowland, Dave" , "Nauman, Chris"

Date: 12/20/2012 12:51

PM

Subject:

Gillespie

v.

13th JCC, et al: US Supreme Court/Response Due

Diana,

The Plainti ff's Notice of Filing the petition

for writ

of certiorari was received in the Legal Department's

Office on

12 18 12

is

attached

as

well

as

the Court's docket indicating a response

is

due,

if

needed, by

January 14 2013. Neither a copy of the petition nor "separate Volume Appendices" accompanied the

Notice.


16/38

Legal Department

800 East Twiggs Street, Suite 603


Telephone: (813) 272-6843

Gillespie

v

13 JCC.USC.121220.pdf


17/38

PAM BONDI

ATTORNEY GENERAL

STATE OF FLORIDA

OFFICE OF

THE

ATTORNEY GENERAL

General

Civil Litigation -

Tampa Bureau

Kenneth

V. Wilson

Assistant Attorney General

501

East

Kennedy Blvd., Suite 1100

Tampa

FL

33602

Phone (813) 233-2880 Fax (813) 233-2886

Kpnnp II.

i l ~ n n r D m v f l n r r l n l p p n l _ r n m

January 8 2013

David Rowland

General Counsel

Administrative Office of the Courts

Thirteenth Judicial Circuit

of

Florida

800

East Twiggs Street, Suite

603


Re:

Neil Gillespie

v

Thirteenth Judicial Circuit et af

U.S. District Court: 5: 1O-cv-503-0c-l OTBS, 5: l1-cv-539

1J S Court of Appeals for the Eleventh Circuit: 12-11028, 12-11213

lJ.S. Supreme Court Application, No. 2A215

U.S. Supreme Court Petition, No. 12-7747

Dear Attorney Rowland:

I have been assigned to review the recent tiling and notification from Plaintiff concerning

his Petition for Writ

of

Certiorari C'Petition ) and Motion for Leave

to

Proceed In Forma

Pauperis (' 'Motion ) before the United States Supreme ~ o u r t Docket No. 12-7747.

PlaintitT's letter, as

well

as,

the

docket

of

Proceedings and Orders before the U.s.


18/38


19/38


20/38


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Page 2 of 2


23/38

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1Z64589FP297520287 Updated: 12/11/2012 8:17 A.M. Eastern Time

On Vehicle fo r Delivery Today

Change Delivery

Request Status Updates

Addi ti onal In fo rmat ion

Shipped/Billed On: 12/10/2012

Type: Package

Weight: 1.00 lb

Shipment Progress What's This?

Scheduled Delivery:

Tuesday, 12/11/2012, By End of Day

Last Location:

Tampa, FL, United States, Tuesday, 12/11/2012

Location DateLocal

TimeAct ivi ty

Tampa, FL, United States 12/11/2012 6:58 A.M. Out For Delivery

12/11/2012 3:30 A.M. Arrival Scan

Orlando, FL, United States 12/11/2012 2:30 A.M. Departure Scan

Orlando, FL, United States 12/10/2012 11:46 P.M. Arrival Scan

Ocala, FL, United States 12/10/2012 9:24 P.M. Departure Scan

12/10/2012 7:11 P.M. Origin Scan

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To: TAMPA, FL, US

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Neil Gillespie

From: "UPS Quantum View" To:

Sent: Monday, December 10, 2012 6:14 PMSubject: UPS Ship Notification, Tracking Number 1Z64589FP297520287

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Important Delivery Information

Scheduled Delivery:11-December-2012

Shipment Detail

Ship To:

David A. Rowland, Court CounselThirteenth Judicial Circuit Florida800 E. Twiggs Street, Suite 603

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26/38

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Proof of Delivery

Tracking Number: 1Z64589FP291778029

Service: UPS GroundWeight: 1.00 lb


Delivered On: 12/18/2012 10:44 A.M.

Delivered To: 800 E TWIGGS ST

TAMPA, FL, US 33602

Signed By: DAVIS

Left At: Front Desk

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Dear Customer,

This notice serves as proof of delivery for the shipment listed below.

Thank you for giving us this opportunity to serve you.

Sincerely,

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Tracking results provided by UPS: 05/13/2013 7:45 P.M. ET

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1Z64589FP291778029

Updated: 05/11/2013 10:20 P.M. Eastern Time

Delivered


Repor t a Claim



Type: Package

Weight: 1.00 lb


Delivered On:Tuesday, 12/18/2012 at 10:44 A.M.

Left At:

Front Desk

Signed By:

DAVIS

Proof of Delivery


To:

800 E TWIGGS ST

TAMPA, FL, 33602, US

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Neil Gillespie


Sent: Tuesday, December 18, 2012 12:08 PMSubject: UPS Delivery Notification, Tracking Number 1Z64589FP291778029



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At the request of Nei l J. Gil lespie, this noticeis to confirm that the following shipment hasbeen delivered.


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1Z64589FP291778029 Updated: 12/17/2012 10:39 P.M. Eastern Time

In Transit: On Tim eBusiness

Day(s) Left1

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Type: Package

Weight: 1.00 lb


Scheduled Delivery:

Tuesday, 12/18/2012, By End of DayLast Location:

Departed - Ocala, FL, United States, Monday, 12/17/2012

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Neil Gillespie


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Scheduled Delivery:18-December-2012

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David A. Rowland, Court CounselThirteenth Judicial Circuit Florida800 E. Twiggs Street, Suite 603

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The UPS Store #5520

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Dec

2012 5:18

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35/38


36/38

Supreme Court of the

United States

Neil

J.

Gillespie

(Petitioner)

v

No. 12-7747

Thirteenth

Judicial Circuit, et

ale

(Respondent)

To

Counsel for Respondent:

NOTICE IS HEREBY GIVEN pursuant to Rule 12.3 that a petition for a writ

of

certiorari in the above-entitled case was filed in the Supreme Court

of

the United States

on December 10, 2012, and placed on the docket December 14, 2012. Pursuant to Rule

15.3, the due date for a

brief

in opposition is Monday, January 14, 2013.

If

tile due date

is a Saturday, Sunday, or federal legal holiday, the brie f is due on the next day that is not

a Saturday, Sunday or federal legal holiday.

Unless

the

Solicitor

General

of

the

United States represents the

respondent, a waiver form is enclosed and should be sent to the Clerk only in

the

event

you do

not

intend

to file a response to

the

petition.


37/38

WAIVER

Supreme

Court

ofthe

United States

No. 12-7747

Neil

J

Gillespie v

Thirteenth

Judicial

Circuit,

et

al.

(petitioner)

(Respondents)

I DO NOT INTEND TO FILE A RESPONSE

to the petition for a writ of certiorari unless

one is requested by

the

Court.

Please check one of the following boxes:

o Please enter

my appearance

as Counsel of Record for all respondents.

o There

are

multiple respondents,

and

I do not represent all respondents. Please

enter

my

appearance as Counsel of Record for the following respondent(s):

I certify

that

I

am

a

member

of the

Bar

of the

Supreme Court of the United

States (Please

explain name

change since

bar

admission):

Signature _

Date: _

(Type or print) Name _


38/38

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Diana R. Esposito Chief-Assistant Attorney General records request

Documents

Transcript of Diana R. Esposito Chief-Assistant Attorney General records request